ML20149L191

Requests Exemption from Requirement of 10CFR73.55, Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage

ML20149L191
Person / Time
Site:	Clinton
Issue date:	01/14/1997
From:	Connell W ILLINOIS POWER CO.
To:	Miraglia F NRC (Affiliation Not Assigned)
References
NUDOCS 9707310180
Download: ML20149L191 (7)

Text

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R WC-015-97 January 14, 1997 10CFR73.5 Docket No. 50 461 Mr. Frank J.Miraglia Acting Director, OfEce ofNuclear Reactor Reguladon U.S.NuclearRegulatory Comminaion Washington,D.C. 20555

Subject:

Request for F==:* ion firom 10CFR73.55(d)(5),

Use ofF=ad C*wnatry Devices (Ria-series)

Dear Mr. Miraglia:

The purpose of this letter is for Illinois Power (IP) to request an exemption fiom certain requirements of 10CFR73.55, " Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage," for the Clinton Power Station (CPS). NRC approval of this exemption request will permit the haplementation of an alternative unescorted access control system which would ali=iaate the need to issue and retrieve key card badges at the CPS protected area entrance / exit locations. The implementation of a biometrics access control system as an alternative unescorted access control system will not affect the ability of the CPS physical protection system to protect against the design basis threat of radiological sabotage and will allow the general performance requirements of 10CFR73.55 to continue to be met. Therefore, the standards of 10CFR73.5, "Specinc Exemptions," are satisfied.

A*=^==* 1 to this letter provides speci6c details conceming the subject

==aation request. Attachment 2 to this letter provides proposed changes to the CPS Physical Security Plan (PSP) for biometrics access control system implementation.

The an==1 savings vad to be realized from the implementation of a biometrics access control system at CPS is wie h=taly $112,000; therefore, IP requests consideration of this===ation requect be prioritized as a Cost BeneficialIJcensing e" o o @

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Action (CBLA). IP requests that consideration of this action be reviewed on a schedule

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=% to support implementatian of the CPS biometrics access control system beginning May 1,1997.

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3ikeGrftoft116ensing Pmjost Manager NRC Resident OfEce, V-690 (w/o Attachment 2)

Regional Adadnistrator,RegionIII,USNRC Illinois Department ofNuclear Safety (w/o Attachment 2)

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Request for Exemption 10CFR73.55(d)(5)

Pursuant to 10CFR73.5, Illinois Pcwer (IP) requests an exemption Rom certain requirements of 10CFR73.55, "Requirmanen for Physical Protection ofilcensed Activities in Nuclear Power Reactors Against Radiological Sabotage," for the Clinton Power Station (CPS). 10CFR73.55(d)(5) states, in part, that an individual not employed by the licensee (i.e., contractors) may be authorimd access to protected areas without escort pid.ded the individual, "... receives a picture badge upon entrance into the protected area which must be returned upon exit from the protected ama..." As discussed below, approval of this exemption will permit the implamantatian of an alternative -W access control system which would eliminate the need to issue and retrieve key card badges at the CPS protected area (PA) entrance / exit locations, and would allow all individuals, including licensee employees and contractors, with unescorted access authorization to keep their key card badges with them when departing the PA. An exemption from 10CFR73.55(d)(5) is required to permit contractors to retain key card badges instead of returning them when exiting the PA.

IP proposes to implement a hand geometry system (biometrics) to control unaamrted access into the CPS PA and believes the stan<tards of 10CFR73.5, " Specific Exemptions,"

are satis 6ed in this request. Since a biometrics access control system would require the use of both the key card badge and a hand geometry system to gain access to the PA, the proposed system would continue to provide for a positive veri 6 cation process prior to entering the PA. Potentialloss of a key card badge by an individual, u a result of removing the key card badge from the PA, would not enable an unauthorized entry into the CPS PA.

u, 10CFR73.55(a), " General Performance Objective and Requiran=ata." states that, "The licanaam shall establish and maintain an onsite physiW protection system and security organization which will have as its objective to provide high assurance that activities involving special nuclear material are not inimical to the common defense and security and do not constitute an unreasonable risk to the public health and safety." 10CFR73.55(d),

" Access Requirmnarna," further speci6es that,

"(1)

The licensee shall control all points of personnel and vehicle access into a protected area."

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as well as, A munbered picture badge Watin tion system shall be used for all individuals

"(5) ca who are authorized access to protemed areas without escort. An individual not employed by the licensee but who requires Requent and =ta=W access to protected and vital areas may be authorized access to such areas without escort provided that he receives a picture badge upen e= trance into the protected area which nest be returned upon exit Rom the 3,.h ares..."

Currently, naamaatted access into the CPS PA is controlled through the use of a picture key card badge. Positive antincarian ofpersonnel authorized and requesting access to the PA is established by security personnel making a visual comparison of a picture key card badge and the individual requesting access. Key card badges are currently not removed from the PA and are issued, stored, and retrieved at the CPS Operations Gatehouse (OGH) (the CPS CraA Security Portal is also utilized c an PA entrance / exit location during maior plant outages with key card badges being issued, stored, and retrieved at thislocation).

Under the proposed system, each individual who is authorized unescorted access to the CPS PA will have the physical characteristics of their hand (band geometry) registered with their key card badge munber in the security access control system Since no individual can use a picture key card badge to gain PA access except the individual whose hand geometry has been registered to that key card badge, individuals (' cluding m

contractors) will be allowed to retain their key card badge when exiting the PA. All other PA access processes, including search function capability and access revocation, will remain the same. Since key card badges will be removed &om the PA, only the need to issue, skvc, and store key card badges at PA entrance locations will be eliminated by implementation of the proposed system A security force member responsible for the last access control function to the PA will continue to be positioned within a bullet-resisting structure for the purpose of controlling admission to the PA.

The proposed system can also be used for persons requiring escorted PA access (i.e.,

visitors). Use of the '.nand geometry system by personnel who require escorted access will be electronically lirled to the assigned escort at the entrance to the PA to ensure unauthorized access to the PAis not permitted.

IP understands that the basis for the wording in 10CFR73.55(d)(5), requiring individuals not employed by IP to receive and return their key card badges at the PA entrance / exit, was to ensure that the key card badges could not be compromised or stolen by being taken offsite with a resulting risk that unauthorized persons could potentially enter the PA.

Under the proposed system, individuals not employed by IP and requiring toquent and SAFEGUARDS INFORMATION ascussenomensenwas mosABAsE000Usager

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=t-id PA access would be eBowed to take their key card badges offsite. However, both the key card badge and the hand geometry would be necessary for access into the j

PA. It should be noted that even if a key card badge were to be compromised or stolen, j

j access to the PA would not be provided without the hand geometry of the person l

registered to the key card badge. In addition, key card badges are deactivated upon 1

exiting the PA and cannot be used for vital area access.until reactivated by a valid hand geometry match at the PA entrance IP maintains that the proposed system would provide i

for a combination ofidentity verification processes that are superior to the existing i

Process i

i 10CFR73.5 Rannirennents l

The standards set forth in 10CFR73.5 e 4ds that specific exemptions will be granted l

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which are authorized by law; will not endanger life or property or the common defense and somrity; and, are otherwise in the public interest.

l IP believes that the activities to be coaAw*M under this exemption are clearly authorized by law and are consistent with the common defense and security. IP also believes the remaining standards of 10CFR73.5 are demonstrated by the following discussion ofhow IP will continue to meet the General Performanna Objective and Requirements of i

10CFR73.55(a) when the exemption is granted.

i 10CFR73.55(a) specifies that the NRC may sathorize a licensee to provide measures for protection for radiological sabotage other than those required by 10CFR73.55. 'Ihis can be accomplished if the licensee demonstrates that: the measures have the same high j

assurance objective as specified in the ryMaa; that the overall level of system l

performance provides protection against radiological sabotage equivalent to the i

regulation; and, meets the general p Lc ee requirements of10CFR73.55.

These standards are satis 6ed as described below.

i Assurance Obiective As discussed in AmericanNational Standard, ANSI /ANS-3.3," Security forNuclear Power Plants," identification ofindividuals authorized access without escort can be accomplished by the use of, "... a device that reads fingerprints, handprints, or some other unique physical feature." Under the proposed system, each individual who is i

authorized unannarted protected / vital area access will have the physical characteristics of j

their hand registered with their key card badge. Visual verification of a picture key card j

badge will be replaced with a hand geometry system which provides for a non-transferable i

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j manna ofidantifying personnel, coupled with the use of a key card badge reader. The current IP access control process for id=J irg individuals meets ANSI /ANS-3.3 criteria i

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The proposed hand geometry access control process, as well, meets the ANSI /ANS-3.3 identification criteria.

l ne hand geometry systeun is superior to the current process because it provides a non-j transferable maana ofidentifying personnel, unlike photographs containad on a key card badge Duririg the registration process, hand measuramants are made. His forms a j

tanplate of the user's hand which is stored for later use in the actual verification process j

A registered user enters his/her key card badge into the card reader and places the hand on the measuring surface. De system detects when the hand is properly positioned and then I

records an image ne unique characteristics are extracted Dom this image and compared with the previously stored template.

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l' Because of the above-mantioned characteristics, the biometrics access control system will provide the same high assurance objective regarding onsite physical protection.

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System Performance t

l De hand geometry equi,a==* selected for use at Clinton Power Station will meet a i

detection probability ofninety percent with a ninety-five percent confidence level. Testing l

conducted by Sandia Nationallaboratories (Sandia Report, "A Performance Evaluation of i

Biometrics Identification Devices," SAND 91- 0276 UC-906 Unlimited Release, June l

1991) demonstrated that hand geometry equipment possesses strorng performance characteristics and is capable of meeting the proposed detection probability and confidence level. Based on the results of the Sandia report and on experience gained at Clinton Power Station under the current photo-identification system, the false-eevea rate for the hand geometry system is at least equal to the current system. IP will implement a j

process for testing the proposed system to ensure continued overall level of performance.

ne hand geometry system will be tested on the same frequency as the seven-day test l

eiwMe for intrusion detecdon aquia==* required by 10CFR73.55(g)(2).

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Failures of the hand geometry key card badge access system will be v -W for by the posting of a Security Force Member at PA entrances to verify identity and access authorization prior to granting access to the PA.

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Lost key card badges will be electronically removed from the access control system, thus 1

a_.wmamboiimed users.

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i General Perfornaance Beauirement 1

l The perfonnance requircunent of 10CFR73.55(d)(1) is to ensure that the licensee controls j

all points of personnel access into the PA. Under the proposed system, F will continue to l

control the points of personnel access into the PA. F believes that the basis for the i

wording in 10CFR73.55(d)(5), regarding individuals not

,k,,.d by the licensee being j

required to receive and return their key card badges at the PA entrance / exit, was to ensure l

that key card badges could not be compromised or stolen by being taken offsite, resulting in unauthorized persons potantially gaining unauthorized access to the PA. Under the proposed system, individuals not employed by 2 (the licensee) and requiring 9equent and extended access to the CPS PA would be allowed to take their key card badges offsite However, both the key card badge and hand geometry would be necessary for access into i

the CPS PA. F points out that even if a key card badge were to be compromised or j

stolen, CPS PA access would not be provided withen the hand geometry of the person registered to that key card badge.

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All required PA access processes, " cluding search function capability and access m

l revocation, will rammin the same. The CPS PA access process will cand== to be under the observation of secunty personnel located within a bullet-resisting structure for the j

purpose of controlling admission to the CPS PA. Key card badges will continue to be I

displayed by all individuals while inside the PA. The processes required to issue, retrieve, j

and store key card badges at the PA entrance and exit will be eliminated Implementation of the biometrics access control system will continue to meet the general 4

l performance requirements of 10CFR73.55(d)(5).

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